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By Jxme 2009, Ms. Johns began working in the ofBce full-time, earning
$4500/month. Ms. Johns was earning much less than she would normally have made
working in the financial services industry; however, she put her other career on hold
to dedicate all her time and energy to the Tea Party Express project, with the hopes
that she would be fairly compensated by receiving 5% ofthe fundraising proceeds,
which was still a part ofher agreement with Our Country and the Tea Party Express.
At that time, the Tea Party Express decided to laxmch its first national bus torn-.
17. In or around June 2009, Ms. Johns played a key role in planning a
fundraising dinner at Chops, a restaurant. Most ofthe guests who attended had
responded to invitations that Ms. Johns sent out. The invitations were signed by both
Ms. Johns and Mr. Williams, but 90% ofthe attendees came in response to personal
telephone calls Ms. Johns made in follow-up. The remaining 10% were followers of
Ms. Johns from her days with Move America Forward. Mr. WiUiams took no action to
invite people to the fundraising event. Ms. Johns was never paid any ofthe proceeds
from this fundraising event.

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In approximately Atjgust 2009, Ms. Johns began to complain to Mr.
Wierzbicki about racially and rehgiously discriminatory and derogatory comments
made by Mr. Wilhams. Specifically, Mr. WiUiams would call President Obama an
"Indonesian Muslim welfare thug" amongst other comments.